Professional Documents
Culture Documents
KB VENTURE GROUP, LLC D/b/a CLUB LOVE and LUST and IMRAN A. JAIRAM v. THE CITY OF NEW YORK, Et Al.
KB VENTURE GROUP, LLC D/b/a CLUB LOVE and LUST and IMRAN A. JAIRAM v. THE CITY OF NEW YORK, Et Al.
-against-
Defendants'
Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and IMRAN A.
JAIRAM files this federal complaint against Defendants' THE CITY OF NEW YORK;
BRADLEY; LILY M. FAN; GREELEY FORD and CHARLES A. STRAVALLE, alleging that:
PLAINTIFFS'
domestic limited liability corporation legally operating under the laws of the State of New York,
and at all relevant times operated as an entertainment business 225 47th Street Brooklyn, N.Y.
11220.
DEFENDANT S'
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Authority.
23. Defendant LILY M. FAN, as Commissioner, New York State Liquor Authority.
Authority.
Authority.
BACKGROUND
26. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges prior to October 2014, Red Leopard Lounge, LLC d/b/a Jaguars 3
operated an entertainment business with an On Premises (OP) Liquor License for 225 47th Street
27. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
3
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IMRAN A. JAIRAM allege Red Leopard Lounge, LLC d/b/a Jaguars 3 was owned and managed
by Caucasian males.
28. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM allege Red Leopard Lounge, LLC d/b/a Jaguars 3' target market was
29. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM allege while in business, Defendants' THE CITY OF NEW YORK and
CHARLES A. STRAVALLE rarely if ever issued 'false' violations, 'false' summonses, engaged
in 'false' arrests, legally baseless stop and frisks, 'unlawful' Business Inspections and other
unlawful selective enforcement activities based upon the race and/or national origin of the
business owners, patrons and other stakeholders at Red Leopard Lounge, LLC d/b/a Jaguars 3.
30. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM allege 225 47th Street Brooklyn, N.Y. 11220, is located within Defendant
THE CITY OF NEW YORK Brooklyn Community Board No.: 7, encompassing the
neighborhoods of Sunset Park and Windsor Terrace, zip codes 11215, 11220 and 11232.
31. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM allege according to Defendant THE CITY OF NEW YORK'S data,
32. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM allege according to Defendant THE CITY OF NEW YORK'S data,
Brooklyn Community Board No.: 7, the population demographics (percentages) includes: 22.0
White (Non-Hispanic), 2.6 Black (Non-Hispanic), 31.6 Asian (Non-Hispanic), 1.8 Other (Non-
4
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33. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM allege according to Defendant THE CITY OF NEW YORK'S data,
Brooklyn Community Board No.: 7, 225 47th Street is located within an Industrial Business
Zone.
34. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM allege after performing some market research, the decision was made to
35. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges the focus was to capture a significant segment of the underserved
target market primarily persons of color culturally connected to the hip-hop community with
36. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges the underserved target market includes celebrities from the sports,
37. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM allege on or about August 6, 2013, there was a public filing within the
New York State Department of State Division of Corporations to establish the domestic limited
liability company.
38. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM allege on or about September 30, 2013, there was a public filing within the
New York State Liquor Authority to establish On-Premises (OP) Liquor Licenses for 225 47th
39. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
5
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IMRAN A. JAIRAM alleges during the times periods, modifications were made to 225 47th
40. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges from January 1, 2011 through May 20, 2018, according to the New
York State Liquor Authority's website, the SLA issued and managed within zip code 11215, 622
41. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges from January 1, 2011 through May 20, 2018, according to the New
York State Liquor Authority's website, the SLA issued and managed within zip code 11220, 431
42. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges from January 1, 2011 through May 20, 2018, according to the New
York State Liquor Authority's website, the SLA issued and managed within zip code 11232, 209
43. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges, according to the New York State Liquor Authority's website,
there's no data to establish the license holder's race and/or national origin.
44. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges, according to the New York State Liquor Authority's website, there
is no data to evaluate selective enforcement due to the license holder's race and/or national
origin.
45. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges, according to the New York State Liquor Authority's website, there
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is no data to evaluate SLA fines and other penalties due to the license holder's race and/or
national origin.
46. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges that in or around October 2014, they opened for business.
47. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM allege shortly thereafter Defendant THE CITY OF NEW YORK through
STRAVALLE began the campaign of harassment to close the business due to the race and/or
national origin of the business owner, its patrons and other stakeholders.
48. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges that Defendant THE CITY OF NEW YORK through Defendants'
the business owners, its patrons and other stakeholders to unlawful selective enforcement
activities despite a previous ruling in Sulkowska v. City of New York, et al., 129 F.Supp. 2d 274
49. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges that despite the ruling in Sulkowska, Defendant THE CITY OF
NEW YORK continue unlawful selective enforcement activities citywide based upon the race
50. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges that despite the ruling in Sulkowska, Defendant THE CITY OF
NEW YORK continue unlawful selective enforcement activities citywide based upon the race
and/or national origin of the business owners, its patrons and other stakeholders.
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51. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges that in or around November 2016, they discontinued a business
52. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges that shortly thereafter, 'false' allegations filed with the NYPD
Internal Affairs Bureau claiming they were paying off the police for protection.
53. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges that shortly thereafter Defendants' THE CITY OF NEW YORK;
II; NAOMI TATIS; CHAD IVERSON; JOSE RUIZ; JOHN LATTANZIO; ROMAN
STRAVALLE began issuing 'false' violations, 'false' summonses, engaged in 'false' arrests,
legally baseless stop and frisks, 'unlawful' Business Inspections and other unlawful selective
enforcement activities based upon the race and/or national origin of the business owner, its
54. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges that Defendants' THE CITY OF NEW YORK; EMMANUEL
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55. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges that throughout this time, they filed several complaints about the
unlawful selective enforcement activities with Defendant THE CITY OF NEW YORK, New
York State Governor Andrew M. Cuomo, New York State Attorney General's Office, Mayor
56. Plaintiffs' KB VENTURE GROUP, LLC dlb/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges that according to the Notice of Pleading dated April 21, 2017, they
were served by the New York State Liquor Authority with a notice of violations dated from
57. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM allege that the Notice of Pleading were based upon the unlawful selective
CHRISTOPHER SHEA; UMAR CHEEMA; PETER P. CIAPPA, II; NAOMI TATIS; CHAD
58. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM allege that Defendants' VINCENT G. BRADLEY; LILY M. FAN and
GREELEY FORD scheduled an administrative hearing within the New York State Liquor
59. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM allege that according to the recommendation of Administrative Law Judge
Craig Porges, the New York State Liquor Authority served them with an amended notice of
pleadings dated September 12, 2017, listing notice of violations dated from November 6, 2016,
60. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM allege that Defendants' VINCENT G. BRADLEY; LILY M. FAN and
GREELEY FORD scheduled an administrative hearing within the New York State Liquor
61. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM allege that throughout this time, Defendant EMMANUEL GONZALEZ
attempted to secure several personal 'benefits' from them including 11 'free' roundtrip tickets on
charter flights to Puerto Rico and a generator for family member or friend Dr. Oscar Caban
62. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges that on or about October 1, 2017, they sponsored a hurricane relief
63. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges that on or about October 4, 2017, while still taking selective
enforcement actions against them, Defendant EMMANUEL GONZALEZ requested that they
deliver a generator for family member or friend Dr. Oscar Caban Badillo, MD 486 Ave Victoria
Aguadilla, PR 00603.
64. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
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to deliver a generator for family member or friend Dr. Oscar Caban Badillo, MD 486 Ave
65. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges that shortly thereafter, while still taking selective enforcement
tickets on charter flights to Puerto Rico, a fair market value of approximately $80k.
66. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
67. Plaintiffs' KB VENTURE GROUP, LLC dlb/a CLUB LOVE and LUST and
68. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM allege that according to the recommendation of Administrative Law Judge
Craig Porges, on October 31, 2017, the New York State Liquor Authority started receiving
69. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM allege that simultaneously, on October 31, 2017, nearly a century after its
passage during the height of Prohibition, New York City's antiquated Cabaret Law has
been repealed.
70. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM allege that according to the statutory history, the Cabaret Law enacted in
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1926 authorized the government to patrol speakeasies, bars, clubs and restaurants which
71. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM allege that prior to its repeal, throughout the city there were only 97 cabaret
72. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM allege that historically, cabaret licenses were notoriously expensive and
time-consuming to obtain.
73. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM allege that the applicant, were subjected to a great deal of government
74. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM allege that unfortunately, known as the 'Black Law' an analysis of the
language clearly indicates the cabaret law banned certain music, such as brass and wind
instruments, that were associated with jazz music and the Black culture.
75. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM allege that according to the recommendation of Administrative Law Judge
Craig Porges, on December 11, 2017, the New York State Liquor Authority started receiving
76. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
of Administrative Law Judge Craig Porges, the New York State Liquor Authority received
`evidence' against them regarding becoming a 'focal point for police attention' and 'failing to
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77. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
Judge Craig Porges, on December 14, 2017 and February 1, 2018, the New York State Liquor
Authority received further 'evidence' against them regarding violating the cabaret law, becoming
a 'focal point for police attention' and 'failing to exercise adequate supervision' over the conduct
78. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges on March 5, 2018, Administrative Law Judge Craig Porges made a
FORD to sustain four (4) charges, (5) charges not sustained. The All sustained (2) charges
related to the cabaret law and the remaining (2) relate to becoming a 'focal point for the police'
79. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges on April 18, 2018, Defendants' VINCENT G. BRADLEY; LILY
M. FAN and GREELEY FORD accepted the ALF S recommendation and moved to cancel their
80. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges that on or about April 24, 2018, Defendant THE CITY OF NEW
YORK through Brooklyn Community Board No.: 7, writing "My community was very
concerned when this business opened several years ago as Jaguars 3 (Red Leopard) and, at the
beginning, there were community complaints about the activities of the patrons and how the
business operated. However, in the past four years our office has received no complaints about
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the operation of the business nor the behavior of the patrons. In fact, we have record of only a
few quality of life complaints in the immediate vicinity and none have identified Love and Lust
81. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges that Brooklyn Community Board No.: 7's position is 'accurate' and
that the business is a 'focal point' of the police and therefore, must be closed.
82. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges on May 16, 2018, Defendants' VINCENT G. BRADLEY; LILY
M. FAN and GREELEY FORD denied their motion for reconsideration to cancel their On-
83. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges on May 30, 2018, through new counsel, they motioned Defendants'
VINCENT G. BRADLEY; LILY M. FAN and GREELEY FORD for reconsideration related to
`selective enforcement.'
84. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
GREELEY FORD never responded to their motion for reconsideration related to 'selective
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enforcement.'
85. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges first and foremost, a careful reading of the ALYS recommendation
86. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges notwithstanding the fact, these charges were not adjudicated in a
timely manner, so as to disadvantage them, there is absolutely no sound legal analysis regarding
87. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges frankly, the ALF S recommendation is legally flawed, internally
inconsistent and based solely upon racial and/or national origin bias against the business owner,
88. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
BRADLEY; LILY M. FAN and GREELEY FORD testing the 'legal sufficiency' of the
recommendation based solely upon racial and/or national origin bias against the business owner,
89. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges from the outset, the ALJ should have not sustained Charges 5 and
6.
90. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges the ALJ failed to protect their due process rights.
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91. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges the ALJ failed to 'judicially notice' the fact that on October 31,
2017, the city repealed the cabaret law and to request further evidence from the New York State
Liquor Authority about whether that results in a voluntary withdraw of those charges or a
92. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges second, the ALJ should not have sustained Charges 7 and 8.
93. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges the ALJ failed to protect their due process rights.
94. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges based upon the 'evidence,' the ALJ did not sustain Charges 1
through 4 and 9. Yet, the ALJ used the same 'evidence' to sustain Charges 7 and 8, which is
legally flawed, internally inconsistent and based solely upon racial and/or national origin bias
95. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and IMRAN A.
CHRISTOPHER SHEA; UMAR CHEEMA; PETER P. CIAPPA, II; NAOMI TATIS; CHAD
GREELEY FORD and CHARLES A. STRAVALLE violated their civil rights under The Civil
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COUNT I
EQUAL PROTECTION — SELECTIVE ENFORCEMENT
IN VIOLATION OF
THE CIVIL RIGHTS ACT OF 1871, 42 U.S.C. § 1983
96. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
97. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
SHEA; UMAR CHEEMA; PETER P. CIAPPA, II; NAOMI TATIS; CHAD IVERSON; JOSE
BRADLEY; LILY M. FAN; GREELEY FORD and CHARLES A. STRAVALLE under color
of law personally interfered with and deprived them of their civil rights.
98. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
CHRISTOPHER SHEA; UMAR CHEEMA; PETER P. CIAPPA, II; NAOMI TATIS; CHAD
17
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99. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
CHRISTOPHER SHEA; UMAR CHEEMA; PETER P. CIAPPA, II; NAOMI TATIS; CHAD
STRAVALLE subjected the business, its patrons and other stakeholders to unlawful selective
enforcement activities despite a previous ruling in Sulkowska v. City of New York, et al.., 129
100. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
CHRISTOPHER SHEA; UMAR CHEEMA; PETER P. CIAPPA, II; NAOMI TATIS; CHAD
STRAVALLE under color of law, they sustained significant business losses, other related costs
and damages.
COUNT II
MONELL CLAIM
IN VIOLATION OF
THE CIVIL RIGHTS ACT OF 1871, 42 U.S.C. § 1983
101. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and IMRAN A.
JAIRAM re-alleges Paragraphs 1 through 100 and incorporates them by reference as Paragraphs
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102. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges Defendant THE CITY OF NEW YORK through its agents caused
their injuries.
103. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and IMRAN A.
JAIRAM alleges Defendant THE CITY OF NEW YORK actions of implementing 'official and
Sulkowska v. City of New York, et al., 129 F.Supp. 2d 274 (S.D.N.Y. January 24, 2001).
104. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and IMRAN A.
JAIRAM alleges Defendant THE CITY OF NEW YORK through its agents deprived them of
105. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and IMRAN A.
JAIRAM alleges Defendant THE CITY OF NEW YORK through its agents' caused them to
COUNT III
FAILURE TO SUPERVISE
IN VIOLATION OF
THE CIVIL RIGHTS ACT OF 1871, 42 U.S.C. § 1983
106. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and IMRAN A.
JAIRAM re-alleges Paragraphs 1 through 105 and incorporates them by reference as Paragraphs
107. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges Defendant THE CITY OF NEW YORK knows to a moral certainty
108. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
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IMRAN A. JAIRAM alleges that the situation either presents the employee with a difficult
choice of the sort that supervision will make less difficult or that there is a history of employees
109. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges that mishandling those situations will frequently cause the
110. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges that because of Defendant THE CITY OF NEW YORK'S failure
to supervise its employees it sustained sustain significant business losses, other related costs and
damages.
COUNT IV
FAILURE TO DISCIPLINE
IN VIOLATION OF
THE CIVIL RIGHTS ACT OF 1871, 42 U.S.C. § 1983
111. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM re-alleges Paragraphs 1 through 110 and incorporates them by reference as
112. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges Defendant THE CITY OF NEW YORK knows to a moral certainty
113. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges that the situation presents the employee with a difficult choice of
the sort either that discipline will make less difficult or that there is a history of employees
114. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
20
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IMRAN A. JAIRAM alleges that mishandling those situations will frequently cause the
115. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges that because of Defendant THE CITY OF NEW YORK'S failure
to discipline its employees it sustained sustain significant business losses, other related costs and
damages.
COUNT V
CONSPIRACY
IN VIOLATION OF
THE CIVIL RIGHTS ACT OF 1871, 42 U.S.C. § 1985(3)
116. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and IMRAN A.
JAIRAM re-alleges Paragraphs 1 through 115 and incorporates them by reference as Paragraphs
117. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges that Defendants' THE CITY OF NEW YORK; EMMANUEL
FAN; GREELEY FORD and CHARLES A. STRAVALLE under color of law, personally
118. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges that Defendants' THE CITY OF NEW YORK; EMMANUEL
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with one another to deprive them of their constitutional right to legally operate an entertainment
business servicing the underserved target market primarily persons of color culturally connected
to the hip-hop community with more than $500 billion in discretionary income to spend upon
entertainment.
119. Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
IMRAN A. JAIRAM alleges that Defendants' THE CITY OF NEW YORK; EMMANUEL
FAN; GREELEY FORD and CHARLES A. STRAVALLE, caused them to sustain significant
JURY TRIAL
Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and IMRAN A.
Wherefore, Plaintiffs' KB VENTURE GROUP, LLC d/b/a CLUB LOVE and LUST and
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IMRAN A. JAIRAM demands compensatory and punitive damages from Defendants' THE
CHEEMA; PETER P. CIAPPA, II; NAOMI TATIS; CHAD IVERSON; JOSE RUIZ; JOHN
determined at trial, plus available statutory remedies, both legal and equitable, interests and
costs.
By:
Eric Sanders (ES0224)
Website: http://www.thesandersfirmpc.com
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